Vulnerable Customer Policy

1. POLICY STATEMENT

1.1 Our Commitment

Unicorn Currencies Limited (Canada) and Unicorn Currencies Ltd (United Kingdom) (collectively "Unicorn", "we", "us", or "our") are committed to treating all clients fairly, ethically, and with dignity and respect.

We recognize that some of our clients—including business owners, directors, and authorized signatories of corporate clients—may experience circumstances that make them vulnerable to harm, particularly financial harm. These circumstances can affect their ability to engage with our services effectively, make informed decisions, or protect their own interests.

This Vulnerable Customer Policy establishes our framework for:

(a) Identifying clients who may be in vulnerable circumstances;

(b) Understanding the specific needs of vulnerable clients;

(c) Adapting our services, communications, and processes to meet those needs;

(d) Training our staff to recognize and respond appropriately to vulnerability;

(e) Monitoring outcomes to ensure vulnerable clients receive fair treatment and good outcomes;

(f) Continuously improving our approach through feedback and review.

1.2 Regulatory Context

This policy aligns with:

(a) FCA Consumer Duty (effective July 31, 2023): The Financial Conduct Authority's Consumer Duty requires firms to act to deliver good outcomes for retail customers, including understanding and responding to the needs of vulnerable customers;

(b) FCA Guidance on Fair Treatment of Vulnerable Customers (FG21/1, February 2021): Comprehensive guidance on identifying, understanding, and responding to vulnerability;

(c) Treating Customers Fairly (TCF): Long-standing FCA principle requiring fair treatment throughout the customer lifecycle;

(d) Equality Act 2010 (UK): Protection against discrimination based on protected characteristics including disability, age, and other factors that may relate to vulnerability;

(e) Canadian Human Rights Act and provincial human rights legislation: Requirements for accommodation and equitable treatment;

(f) Accessibility for Ontarians with Disabilities Act (AODA) and similar provincial legislation: Requirements for accessible services;

(g) FINTRAC Guidance on Politically Exposed Persons and Vulnerable Persons: Recognition of vulnerability in anti-money laundering context.

1.3 Scope and Application

This policy applies to:

(a) All client interactions: From initial contact and onboarding through ongoing service delivery and account closure;

(b) All client types: While Unicorn primarily serves business clients (B2B), we recognize that business owners, directors, sole traders, and authorized signatories are individuals who may experience vulnerability;

(c) All channels: Telephone, email, online portal, video calls, and in-person meetings;

(d) All employees: Every team member has a role in identifying and supporting vulnerable clients;

(e) Third-party partners: Where appropriate, we work with banking partners and introducers to ensure vulnerable clients receive consistent, appropriate support.

1.4 B2B Context and Individual Decision-Makers

Important Note on B2B Services:

While Unicorn provides services to corporate clients (companies, partnerships, trusts), the individuals making decisions on behalf of those entities—business owners, directors, CFOs, treasurers, authorized signatories—are human beings who may experience vulnerability.

Examples in B2B context:

• A sole proprietor experiencing bereavement while managing business foreign exchange needs;

• A small business owner with mental health challenges during periods of financial stress;

• An elderly director with declining cognitive capacity making decisions about forward contracts;

• A business owner facing financial difficulties, debt problems, or insolvency;

• An authorized signatory with limited financial literacy pressured into complex hedging products;

• A new entrepreneur with English as a second language struggling to understand foreign exchange terms and conditions.

This policy recognizes that vulnerability can affect business decision-makers just as it affects retail consumers, and we adapt our approach accordingly.

2. UNDERSTANDING VULNERABILITY

2.1 Definition of Vulnerability

A vulnerable customer is someone who, due to their personal circumstances, is especially susceptible to harm—particularly when a firm is not acting with appropriate levels of care.

Vulnerability is:

(a) Situational and contextual: Not a fixed characteristic; individuals may move in and out of vulnerable circumstances;

(b) Multifaceted: Can arise from health, life events, resilience, and capability factors (see Section 2.2);

(c) Variable in impact: The same circumstance may affect different people differently;

(d) Temporary or permanent: May be short-term (e.g., bereavement) or long-term (e.g., chronic illness);

(e) Often hidden: Many clients will not self-identify as vulnerable or disclose their circumstances.

Key Principle: Vulnerability is not about labeling individuals; it is about understanding circumstances that may increase the risk of harm and adapting our services to prevent that harm.

2.2 Drivers of Vulnerability (HRRC Framework)

The FCA identifies four key drivers of vulnerability, which can overlap and interact:

2.2.1 Health

Physical or mental health conditions or illnesses that affect ability to carry out day-to-day tasks or make decisions.

Examples relevant to our business clients:

(a) Physical health conditions:

• Serious illness (cancer, heart disease, chronic conditions);

• Disability affecting mobility, vision, hearing, or communication;

• Hospitalization or recovery from surgery/injury;

(b) Mental health conditions:

• Depression, anxiety, stress disorders;

• Bipolar disorder, schizophrenia, or other serious mental illnesses;

• Addiction or substance abuse issues;

• Cognitive impairments (dementia, Alzheimer's, traumatic brain injury);

(c) Impact on our services:

• Difficulty understanding complex foreign exchange products (forward contracts, options);

• Impaired judgment regarding risk or timing of transactions;

• Difficulty managing deadlines for funding or settlement;

• Communication challenges (phone calls, written instructions).

2.2.2 Resilience

Low ability to withstand financial or emotional shocks.

Examples relevant to our business clients:

(a) Financial resilience issues:

• Business financial difficulties, cash flow problems, or insolvency risk;

• Over-indebtedness or mounting business debts;

• Recent business failure or loss of major client/contract;

• Unexpected large expenses (litigation, regulatory penalties);

• Seasonal businesses facing low-income periods;

(b) Emotional resilience issues:

• High levels of stress related to business performance;

• Pressure from creditors, investors, or business partners;

• First-time business owners facing steep learning curves;

• Entrepreneurs experiencing burnout;

(c) Impact on our services:

• Pressure to take excessive foreign exchange risks to solve business problems;

• Desperation leading to poor decision-making about rate locking or hedging;

• Difficulty absorbing losses from market movements or cancelled transactions;

• Vulnerability to fraud or exploitation by unscrupulous advisors.

2.2.3 Life Events

Major life events that can affect ability to engage effectively with financial services.

Examples relevant to our business clients:

(a) Bereavement: Death of business partner, co-director, spouse, or close family member;

(b) Relationship breakdown: Divorce or separation affecting business ownership or operations;

(c) Caring responsibilities: Becoming a carer for ill family member, affecting time and mental capacity;

(d) Job loss or income shock: Loss of key employment (relevant for sole traders or small business owners dependent on few income sources);

(e) Business transitions: Retirement, succession planning, sale or closure of business;

(f) Immigration or relocation: Moving to UK/Canada and navigating unfamiliar financial systems;

(g) Domestic abuse: Experiencing coercive control or economic abuse affecting business decisions;

(h) Legal or regulatory issues: Facing litigation, regulatory investigation, or enforcement action;

(i) Natural disasters or emergencies: Fire, flood, pandemic affecting business premises or operations.

(c) Impact on our services:

• Distraction and reduced capacity to focus on foreign exchange decisions;

• Need for urgent transactions during crisis periods;

• Changes in authorized signatories or decision-making authority;

• Need for compassionate communication and flexible processes.

2.2.4 Capability

Low knowledge or confidence in managing finances, or low capability in other relevant areas (e.g., literacy, digital skills).

Examples relevant to our business clients:

(a) Financial capability issues:

• Limited understanding of foreign exchange markets, rates, and risks;

• Lack of experience with forward contracts, hedging, or derivatives;

• Difficulty understanding margin requirements or mark-to-market concepts;

• First-time importers/exporters unfamiliar with cross-border payments;

• Confusion about fees, spreads, and total costs of transactions;

(b) Literacy and numeracy issues:

• Low literacy affecting ability to read and understand contracts or terms;

• Numeracy challenges affecting understanding of exchange rate calculations;

• Difficulty with financial projections or exposure calculations;

(c) Digital capability issues:

• Unfamiliarity with online banking portals or transaction platforms;

• Difficulty navigating websites, emails, or electronic signatures;

• Lack of access to reliable internet or devices;

• Concerns about online security and fraud;

(d) Language barriers:

• English as a second language (ESL) affecting comprehension of technical terms;

• Preference for communication in languages other than English;

• Cultural differences affecting understanding of UK/Canadian business practices;

(e) Age-related capability issues:

• Elderly business owners with declining cognitive function or resistance to digital channels;

• Very young or inexperienced entrepreneurs lacking business and financial knowledge;

(f) Impact on our services:

• Misunderstanding of product risks and suitability;

• Inability to make informed decisions about foreign exchange strategies;

• Signing contracts or agreeing to terms without full understanding;

• Vulnerability to mis-selling or inappropriate product recommendations;

• Difficulty accessing or using online services.

2.3 Intersectionality and Multiple Vulnerabilities

Clients may experience multiple drivers of vulnerability simultaneously, which can compound risks and challenges.

Examples:

• Elderly business owner (capability) experiencing bereavement (life event) and financial distress (resilience);

• Small business owner with mental health issues (health) facing business failure (resilience) and limited financial knowledge (capability);

• Recent immigrant entrepreneur (capability - language/digital) starting first business (capability - inexperience) with limited financial reserves (resilience).

Our approach recognizes intersectionality and tailors support to address multiple vulnerability drivers together.

2.4 Temporary vs. Permanent Vulnerability

(a) Temporary vulnerability: Short-term circumstances (e.g., recovery from surgery, bereavement period, temporary cash flow crisis) that improve over time;

(b) Permanent or long-term vulnerability: Ongoing circumstances (e.g., chronic illness, permanent disability, persistent low income) requiring sustained accommodations.

Our approach adapts to the expected duration of vulnerability, with regular reviews to reassess needs.

3. IDENTIFYING VULNERABLE CLIENTS

3.1 Proactive Identification

We use multiple methods to identify clients who may be in vulnerable circumstances:

3.1.1 Client Onboarding and Application Forms

During account opening, we:

(a) Include optional questions inviting clients to disclose circumstances that may require support:

• "Do you have any physical or mental health conditions that may affect how you engage with our services?"

• "Are you experiencing any life events or circumstances that may require additional support from us?"

• "Do you have any accessibility needs or preferences for how we communicate with you?"

• "Is English your first language? Would you prefer communications in another language?"

(b) Explain why we ask: To provide appropriate support and ensure good outcomes, not to deny services or treat clients differently in a discriminatory way;

(c) Emphasize confidentiality: Information is handled sensitively and used only to improve service delivery;

(d) Make disclosure optional: Clients are not required to disclose vulnerability, and non-disclosure does not affect access to services.

3.1.2 Ongoing Monitoring and Staff Observations

Our staff are trained to identify potential indicators of vulnerability through:

(a) Communication patterns:

• Difficulty understanding explanations of products or processes;

• Repeatedly asking the same questions or expressing confusion;

• Apparent distress, anxiety, or emotional difficulty during conversations;

• Disclosure of personal circumstances (bereavement, illness, financial problems);

• Language barriers or requests for translation;

• Difficulty hearing or understanding phone conversations;

(b) Transaction patterns:

• Unusual or uncharacteristic transaction activity;

• Apparent desperation or urgency inconsistent with business needs;

• Requests for products that appear unsuitable for the client's risk profile or business;

• Difficulty meeting margin calls or funding deadlines;

• Frequent cancellations or changes to instructions;

(c) Account management indicators:

• Missed appointments or failure to respond to communications;

• Requests for extensions, payment plans, or forbearance;

• Power of attorney (POA) arrangements or third-party representatives;

• Changes in authorized signatories or contact details suggesting life changes;

• Expressions of financial stress or business difficulties.

3.1.3 Data and Analytics

We use data analytics to identify patterns that may indicate vulnerability:

(a) Age: Very young (under 30) or elderly (over 70) business owners may face capability or health-related vulnerabilities;

(b) Geographic location: Areas with higher deprivation indices or lower financial literacy rates;

(c) Business type and sector: Sectors facing economic stress (e.g., hospitality during pandemic, retail facing e-commerce disruption);

(d) Transaction history: Patterns suggesting financial distress (declining volumes, smaller transactions, frequent cancellations);

(e) Customer service interactions: Frequency and nature of support requests.

Important: Data analytics identify potential vulnerability for further assessment; they do not result in automatic assumptions or discriminatory treatment.

3.1.4 External Information Sources

Where appropriate and with client consent, we may consider:

(a) Credit reference data: Indicators of financial distress (defaults, CCJs, insolvency);

(b) Public records: Insolvency filings, company dissolution notices;

(c) Regulatory databases: Disqualified directors, enforcement actions;

(d) Third-party referrals: Information from introducers, accountants, or other trusted parties (with client consent).

3.2 Client Self-Disclosure

We encourage and facilitate client self-disclosure of vulnerability through:

(a) Clear communication about why we ask about vulnerability and how we use information;

(b) Multiple disclosure opportunities: At onboarding, during service interactions, and through proactive outreach;

(c) Accessible channels: Phone, email, secure messaging, in-person meetings, online forms;

(d) Trusted relationships: Building rapport so clients feel comfortable disclosing circumstances;

(e) Non-judgmental approach: Responding to disclosures with empathy, support, and reassurance;

(f) Regular check-ins: Periodic reviews asking "Has anything changed in your circumstances that we should be aware of?"

3.3 Sensitive Handling of Vulnerability Information

When vulnerability is identified:

(a) Record on client file: Document vulnerability drivers, specific needs, and agreed accommodations in secure, confidential client records;

(b) Flag for visibility: Use internal systems to flag vulnerable clients so all staff interacting with the client are aware;

(c) Limit access: Restrict access to vulnerability information to staff with legitimate need-to-know;

(d) Obtain consent: Where necessary, obtain explicit consent before recording or sharing sensitive health or personal information;

(e) Regular review: Reassess vulnerability status periodically (at least annually or when circumstances change);

(f) Respect privacy: Never disclose vulnerability status to third parties without client consent (except where legally required).

3.4 Staff Training on Identification

All client-facing staff receive training on:

(a) Vulnerability indicators: How to recognize signs of vulnerability in conversations and transactions;

(b) Asking sensitively: How to ask about vulnerability without causing offense or distress;

(c) Active listening: Listening for clues, expressions of difficulty, or requests for help;

(d) Empathy and respect: Responding to vulnerability disclosures with compassion and without judgment;

(e) Escalation procedures: When and how to escalate concerns to managers or the Vulnerable Customer Lead.

4. SUPPORTING VULNERABLE CLIENTS

4.1 Principles of Support

Our approach to supporting vulnerable clients is guided by:

(a) Individuality: Tailoring support to the specific needs of each client, not applying one-size-fits-all solutions;

(b) Dignity and respect: Treating vulnerable clients with the same respect as all clients, avoiding paternalism or assumptions;

(c) Empowerment: Supporting clients to make informed decisions and maintain control, not making decisions for them;

(d) Proportionality: Providing appropriate levels of support without over-intervening or restricting access to services;

(e) Flexibility: Adapting processes, communications, and timelines to accommodate vulnerability;

(f) Proactivity: Anticipating needs and offering support before problems arise;

(g) Consistency: Ensuring all staff provide consistent, high-quality support to vulnerable clients.

4.2 Communication Adjustments

We adapt our communication methods and styles based on client needs:

4.2.1 Language and Clarity

(a) Plain language: Avoiding jargon, technical terms, and complex financial language;

(b) Shorter sentences: Breaking information into digestible chunks;

(c) Explanations and examples: Providing concrete examples to illustrate concepts;

(d) Visual aids: Using charts, diagrams, or screenshots where helpful;

(e) Checking understanding: Regularly asking "Does that make sense?" or "Would it help if I explained that differently?"

(f) Written summaries: Following up verbal conversations with written summaries of key points;

(g) Key facts documents: Providing simplified, one-page summaries of important terms or product features.

4.2.2 Channel and Format Adjustments

(a) Preferred channels: Accommodating preferences (phone vs. email vs. video vs. in-person);

(b) Phone calls over email: For clients with literacy issues or who prefer verbal communication;

(c) Email over phone: For clients with hearing difficulties or who need time to process information;

(d) Video calls: For clients who benefit from visual cues or face-to-face interaction;

(e) Large print: Providing documents in larger fonts for clients with visual impairments;

(f) Alternative formats: Offering audio recordings, accessible PDFs, or other formats upon request;

(g) Translation services: Providing documents in other languages or arranging interpreter services for non-English speakers (key documents available in French, Mandarin, Punjabi, and other common languages upon request).

4.2.3 Timing and Pacing

(a) More time: Allowing longer call times or appointment durations for clients who need extra time;

(b) Multiple touchpoints: Breaking complex information across multiple conversations rather than overwhelming clients in one session;

(c) Cooling-off periods: Providing additional time to consider decisions, beyond standard cooling-off periods;

(d) Flexible deadlines: Extending deadlines for document submission, funding, or other requirements where feasible;

(e) Scheduling accommodations: Scheduling calls or meetings at times convenient for clients (e.g., avoiding hospital appointments, caregiving responsibilities).

4.2.4 Tone and Empathy

(a) Compassionate tone: Expressing empathy and understanding, especially when clients disclose difficult circumstances;

(b) Patience: Remaining patient with clients who need repeated explanations or reassurance;

(c) Non-judgmental: Avoiding judgmental language or attitudes toward financial difficulties or capability issues;

(d) Positive reinforcement: Acknowledging and praising client efforts to understand or engage;

(e) Reassurance: Providing reassurance about security, confidentiality, and our commitment to support.

4.3 Product and Service Adjustments

4.3.1 Product Suitability Assessments

For vulnerable clients, we conduct enhanced suitability assessments before recommending products:

(a) Assess complexity: Evaluate whether the product's complexity is appropriate for the client's capability;

(b) Assess risk: Ensure the client understands and can bear the risks (e.g., forward contracts requiring margin);

(c) Assess needs: Verify that the product genuinely meets the client's business needs, not just sales targets;

(d) Consider alternatives: Explore simpler or lower-risk alternatives (e.g., spot transactions instead of forwards);

(e) Document rationale: Clearly document the suitability assessment and recommendations on the client file;

(f) Second opinion: For complex products (forwards, options), require approval from a senior manager or compliance officer for vulnerable clients.

Enhanced Product Warnings:

For vulnerable clients considering higher-risk products:

• Clear risk warnings in plain language with examples of potential losses;

• Worst-case scenarios clearly explained;

• Cooling-off period (at least 48 hours) before finalizing complex transactions;

• Confirmation of understanding (client signs statement confirming they understand key risks).

4.3.2 Simplified Products and Services

Where appropriate, we offer simplified alternatives:

(a) Spot transactions only: For clients who struggle with forward contract complexity, focusing on simpler spot transactions;

(b) Smaller transaction sizes: Allowing clients to break large transactions into smaller, more manageable amounts;

(c) Guided transaction process: Step-by-step assistance through the transaction process with clear instructions at each stage;

(d) Pre-set limits: Helping clients set transaction limits or rate alerts to manage risk;

(e) Dedicated support: Assigning a dedicated account manager for vulnerable clients requiring ongoing guidance.

4.3.3 Flexibility and Forbearance

For vulnerable clients facing financial difficulties:

(a) Payment plans: Offering installment payment options for margin requirements or fees where feasible;

(b) Deadline extensions: Extending funding deadlines or settlement dates to accommodate cash flow issues (subject to market conditions and regulatory requirements);

(c) Fee waivers: Considering waivers or reductions of cancellation fees, amendment fees, or other charges in cases of genuine hardship;

(d) Renegotiation: Allowing renegotiation of forward contracts experiencing significant mark-to-market losses, where commercially viable;

(e) Hold on collections: Temporarily pausing collection activities for clients facing acute crises (bereavement, serious illness) to allow time for recovery;

(f) Referral to debt advice: Signposting clients to free debt advice services (StepChange, Citizens Advice, Debt Helpline) when appropriate.

Important: Forbearance decisions are made on a case-by-case basis, balancing compassion with commercial realities and regulatory requirements (e.g., AML obligations, market risk management).

4.4 Process Adjustments

4.4.1 Onboarding and KYC

For vulnerable clients, we may:

(a) Assisted onboarding: Provide dedicated support to guide clients through the application process step-by-step;

(b) Document assistance: Help clients gather and submit required KYC documents, explaining what is needed and why;

(c) Alternative verification methods: Accept alternative forms of identification or address verification where standard documents are difficult to obtain;

(d) Home visits or video calls: For clients unable to travel or use digital channels, offer alternative verification methods;

(e) Third-party support: Permit trusted third parties (family members, accountants, advisors) to assist with onboarding, with appropriate authorizations;

(f) Extended timelines: Allow longer onboarding periods to accommodate clients who need more time.

4.4.2 Transaction Execution

For vulnerable clients, we may:

(a) Verbal confirmation calls: Call clients to verbally confirm transaction details before execution, ensuring understanding;

(b) Written confirmations: Provide clear, plain-language written confirmations of all transactions;

(c) Cooling-off reminders: Proactively remind clients of their right to cancel within cooling-off periods;

(d) Rate explanations: Explain how rates are determined and confirm clients understand the rate they are locking;

(e) Settlement reminders: Provide advance reminders of settlement dates and funding requirements with clear instructions.

4.4.3 Complaint Handling

For vulnerable clients making complaints:

(a) Priority handling: Expedite complaint resolution where delays could cause significant distress or harm;

(b) Empathetic response: Ensure complaints are handled with extra sensitivity and understanding;

(c) Clear explanations: Provide plain-language explanations of our findings and decisions;

(d) Reasonable adjustments: Accommodate preferences for communication method or format in complaint correspondence;

(e) Ombudsman signposting: Clearly explain rights to escalate to Financial Ombudsman Service (UK) or ADR Chambers Banking Ombuds Office (Canada).

4.5 Third-Party Support and Referrals

We recognize that some vulnerable clients benefit from third-party support:

4.5.1 Power of Attorney and Authorized Representatives

(a) Acceptance of POA: We accept properly documented Power of Attorney arrangements and third-party mandates;

(b) Verification: We verify the authenticity and scope of POA documents and confirm the attorney's identity;

(c) Communication with attorneys: We communicate with attorneys/representatives as directed, while still seeking to engage with the client where possible;

(d) Safeguarding: We remain alert to potential financial abuse or undue influence by third parties (see Section 4.6).

4.5.2 Professional Advisors

We encourage and facilitate involvement of professional advisors:

(a) Accountants and bookkeepers: Working with clients' accountants to ensure foreign exchange strategy aligns with business accounting and tax needs;

(b) Financial advisors: Coordinating with financial advisors managing clients' broader financial affairs;

(c) Legal advisors: Engaging with solicitors handling business transactions requiring foreign exchange;

(d) Insolvency practitioners: Cooperating with administrators, receivers, or trustees in cases of business insolvency.

4.5.3 Referrals to Support Services

We maintain a directory of support services and provide referrals when appropriate:

(a) Debt advice services:

• UK: StepChange (https://www.stepchange.org), Citizens Advice (https://www.citizensadvice.org.uk), National Debtline (https://www.nationaldebtline.org);

• Canada: Credit Counselling Canada (https://www.creditcounsellingcanada.ca), local non-profit credit counseling agencies;

(b) Mental health support:

• UK: Samaritans (116 123), Mind (https://www.mind.org.uk), NHS mental health services;

• Canada: Crisis Services Canada (1-833-456-4566), Canadian Mental Health Association (https://cmha.ca);

(c) Bereavement support:

• UK: Cruse Bereavement Care (https://www.cruse.org.uk);

• Canada: Canadian Virtual Hospice (https://www.virtualhospice.ca);

(d) Domestic abuse support:

• UK: National Domestic Abuse Helpline (0808 2000 247);

• Canada: Canadian Domestic Homicide Prevention Initiative (https://cdhpi.ca);

(e) Business support:

• UK: Business Debtline (https://www.businessdebtline.org), small business insolvency advice;

• Canada: BDC Advisory Services, Futurpreneur Canada;

(f) Legal advice:

• UK: Law Society Find a Solicitor (https://www.lawsociety.org.uk);

• Canada: Law Society referral services by province;

(g) Financial capability services:

• UK: Money Helper (https://www.moneyhelper.org.uk);

• Canada: Financial Consumer Agency of Canada (https://www.canada.ca/en/financial-consumer-agency.html).

Referral Protocol:

• Provide contact information and brief description of services;

• Emphasize that referrals are suggestions, not endorsements or guarantees;

• Respect client autonomy—clients decide whether to use referral services;

• Follow up (where appropriate) to check if referrals were helpful.

4.6 Safeguarding Against Financial Abuse

Vulnerable clients may be at heightened risk of financial abuse or exploitation. We remain vigilant for warning signs:

4.6.1 Warning Signs of Financial Abuse

(a) Sudden changes in transaction patterns, authorized signatories, or contact details;

(b) Undue influence: Third parties dominating conversations, preventing the client from speaking freely, or pressuring the client to make decisions;

(c) Confusion or distress: Client expressing confusion about transactions they allegedly authorized or payments they don't recognize;

(d) Isolation: Attempts by third parties to isolate the client from advisors, family, or support networks;

(e) Unusual instructions: Transactions that don't align with the client's business profile or known needs;

(f) Coercion indicators: Client appears frightened, anxious, or mentions being pressured;

(g) Deceptive documents: Suspicion that signatures or instructions may be forged or obtained through deception.

4.6.2 Safeguarding Actions

If financial abuse is suspected:

(a) Speak to the client privately: Attempt to speak with the client alone (without third party present) to assess their understanding and autonomy;

(b) Verify instructions: Confirm that instructions genuinely come from the client and reflect their free will;

(c) Escalate to senior management: Immediately escalate concerns to the Compliance Officer or COO;

(d) Pause transactions: Where there is reasonable suspicion of abuse, pause transactions pending investigation;

(e) Suspicious Activity Report (SAR): File a SAR with FINTRAC or the National Crime Agency if the circumstances suggest potential financial crime;

(f) Report to authorities: In cases of suspected criminal abuse (fraud, theft, coercion), report to police or adult safeguarding services;

(g) Support the client: Provide information about support services (Action on Elder Abuse, domestic abuse services, legal aid).

Balancing Autonomy and Protection:

We recognize the tension between respecting client autonomy and protecting them from harm. Our approach:

• Presume capacity: We presume clients have capacity to make decisions unless evidence suggests otherwise;

• Support informed decisions: We focus on ensuring clients understand their decisions, not on preventing decisions we disagree with;

• Intervene when necessary: We intervene only when there is clear evidence of abuse, coercion, or lack of capacity.

5. STAFF TRAINING AND COMPETENCE

5.1 Mandatory Training

All employees receive mandatory training on vulnerable customers:

5.1.1 Induction Training

New employees complete vulnerable customer training within 30 days of hire, covering:

(a) Definition of vulnerability and HRRC framework (Health, Resilience, Life Events, Capability);

(b) FCA Consumer Duty and regulatory expectations;

(c) How to identify vulnerable clients (indicators, data, self-disclosure);

(d) Communication skills (empathy, active listening, plain language);

(e) Support mechanisms and adjustments available to vulnerable clients;

(f) Escalation procedures and when to involve managers or specialists;

(g) Safeguarding against financial abuse;

(h) Case studies and role-play scenarios.

5.1.2 Annual Refresher Training

All employees complete annual refresher training, including:

(a) Updates on policy, regulation, and best practices;

(b) Review of real case studies (anonymized) from our own client base;

(c) Lessons learned from complaints, near-misses, or incidents;

(d) Advanced scenarios and challenging situations;

(e) Feedback on team performance and areas for improvement.

5.1.3 Role-Specific Training

(a) Client-facing teams (sales, customer service): Enhanced training on communication skills, de-escalation techniques, and recognizing vulnerability indicators;

(b) Compliance and risk teams: Training on vulnerability in AML/KYC context, suspicious activity reporting, and safeguarding;

(c) Senior management: Training on governance, oversight, and strategic embedding of vulnerability considerations;

(d) Product teams: Training on designing products and processes that accommodate vulnerability.

5.2 Competency and Assessment

(a) Knowledge tests: Employees complete assessments to test understanding of vulnerability concepts and policies;

(b) Call monitoring: Quality assurance reviews of phone calls and emails assess how staff handle vulnerable customer interactions;

(c) Performance reviews: Vulnerable customer support is a component of annual performance reviews for client-facing staff;

(d) Coaching and feedback: Managers provide ongoing coaching based on observations and customer feedback.

5.3 Specialist Roles

5.3.1 Vulnerable Customer Lead

We designate a Vulnerable Customer Lead (currently held by the Head of Compliance) responsible for:

(a) Overseeing implementation of this policy;

(b) Acting as a point of escalation for complex vulnerability cases;

(c) Providing specialist advice and guidance to staff;

(d) Coordinating training and awareness programs;

(e) Monitoring outcomes and identifying areas for improvement;

(f) Reporting to senior management and the Board on vulnerability matters;

(g) Liaising with FCA, ombudsman services, and industry bodies on vulnerability issues.

5.3.2 Vulnerable Customer Champions

Within each department, we designate Vulnerable Customer Champions who:

(a) Act as first point of contact for colleagues seeking guidance;

(b) Promote awareness and best practices within their teams;

(c) Feed insights and suggestions back to the Vulnerable Customer Lead;

(d) Participate in quarterly champion network meetings to share learning.

5.4 Resources and Tools

We provide staff with tools and resources including:

(a) Vulnerability identification checklist: Quick reference guide for spotting vulnerability indicators;

(b) Communication guides: Tips and templates for communicating with vulnerable clients;

(c) Escalation flowchart: Clear process for escalating vulnerability concerns;

(d) Support services directory: Contact information for referral services;

(e) Intranet resource hub: Repository of policies, guidance, case studies, and training materials;

(f) Access to specialist support: Ability to consult the Vulnerable Customer Lead or external specialists (mental health professionals, accessibility experts) when needed.

6. MONITORING AND OVERSIGHT

6.1 Management Information and KPIs

We track key performance indicators to monitor our treatment of vulnerable customers:

6.1.1 Identification KPIs

(a) Number and percentage of clients identified as vulnerable (by driver: health, resilience, life events, capability);

(b) Method of identification (self-disclosure, staff observation, data analytics);

(c) Demographic analysis: Vulnerable clients by age, geography, business size, sector;

(d) Trends over time: Is identification improving as staff training and awareness increase?

6.1.2 Support and Outcomes KPIs

(a) Support measures provided: Types and frequency of adjustments (communication, product, process);

(b) Product take-up: Do vulnerable clients use products appropriately for their needs? Are there signs of unsuitable product sales?

(c) Transaction outcomes: Cancellation rates, losses, complaints among vulnerable vs. non-vulnerable clients;

(d) Complaint analysis: Number of complaints from vulnerable clients, themes, root causes, resolution times;

(e) Customer satisfaction: Feedback scores and qualitative feedback from vulnerable clients;

(f) Financial outcomes: Are vulnerable clients experiencing fair outcomes (costs, pricing, losses)?

6.1.3 Process KPIs

(a) Training completion rates: Percentage of staff completing required training;

(b) Escalation metrics: Number of cases escalated to Vulnerable Customer Lead, response times;

(c) Policy compliance: Audit findings on adherence to policy requirements;

(d) Third-party referrals: Number of referrals to support services, client uptake and feedback.

6.2 Quality Assurance

(a) Call monitoring: Random sampling of calls with vulnerable clients to assess communication quality, empathy, and appropriateness of support;

(b) Email reviews: Sampling of written communications to vulnerable clients;

(c) File reviews: Audits of vulnerable client files to ensure appropriate documentation, risk assessments, and suitability decisions;

(d) Mystery shopping: Occasional use of mystery shoppers (with vulnerability scenarios) to test staff responses;

(e) Customer feedback: Proactive outreach to vulnerable clients to solicit feedback on their experience.

6.3 Reporting

6.3.1 Management Reporting

(a) Quarterly reports to Senior Management on vulnerability KPIs, incidents, lessons learned, and action plans;

(b) Focus on outcomes: Reporting emphasizes whether vulnerable clients are achieving good outcomes, not just process compliance.

6.3.2 Board Reporting

(a) Semi-annual reports to the Board of Directors covering:

• Vulnerability identification and segmentation;

• Key KPIs and trends;

• Complaints and root cause analysis;

• Product suitability and outcomes;

• Training and competence;

• Policy effectiveness and improvement initiatives;

• Regulatory developments and industry benchmarking;

(b) Board oversight: Board reviews and challenges management on vulnerable customer strategy and outcomes.

6.3.3 Regulatory Reporting

(a) Consumer Duty reporting: As required by FCA, reporting on vulnerable customer outcomes as part of Consumer Duty obligations;

(b) Thematic reviews: Responding to FCA thematic reviews or information requests on vulnerable customers;

(c) FINTRAC reporting: Reporting suspicious activity (including potential financial abuse) to FINTRAC in Canada.

6.4 Internal Audit

(a) Annual audit of vulnerable customer policy compliance by Internal Audit or external auditors;

(b) Audit scope: Identification processes, support measures, training, documentation, outcomes, governance;

(c) Findings and action plans: Management responds to audit findings with corrective action plans and timelines;

(d) Follow-up: Internal Audit validates implementation of corrective actions.

7. GOVERNANCE AND ACCOUNTABILITY

7.1 Roles and Responsibilities

7.1.1 Board of Directors

The Board:

(a) Approves this Vulnerable Customer Policy and material amendments;

(b) Sets the strategic direction and tone from the top on fair treatment of vulnerable customers;

(c) Reviews semi-annual reports on vulnerable customer outcomes;

(d) Challenges management on effectiveness of the vulnerable customer program;

(e) Ensures adequate resources are allocated to support vulnerable customers.

7.1.2 Chief Operating Officer (COO)

The COO:

(a) Has ultimate accountability for implementation and effectiveness of this policy;

(b) Chairs the Vulnerable Customer Working Group (see Section 7.2);

(c) Approves significant forbearance decisions or product adjustments for vulnerable clients;

(d) Reports to the Board on vulnerable customer matters;

(e) Ensures cross-functional collaboration on vulnerability issues.

7.1.3 Vulnerable Customer Lead (Head of Compliance)

The Vulnerable Customer Lead:

(a) Owns and maintains this policy;

(b) Oversees day-to-day implementation;

(c) Acts as escalation point for complex cases;

(d) Coordinates training and awareness programs;

(e) Produces management information and reports;

(f) Identifies trends, risks, and improvement opportunities;

(g) Liaises with regulators and industry bodies.

7.1.4 Heads of Department

Department heads (Sales, Operations, Customer Service, Compliance, Product):

(a) Ensure their teams understand and comply with this policy;

(b) Embed vulnerability considerations into departmental processes and decisions;

(c) Monitor team performance on vulnerable customer support;

(d) Escalate issues and provide feedback to the Vulnerable Customer Lead;

(e) Designate and support Vulnerable Customer Champions in their teams.

7.1.5 All Employees

Every employee:

(a) Understands the definition of vulnerability and how to identify vulnerable clients;

(b) Treats vulnerable clients with empathy, dignity, and respect;

(c) Provides appropriate support and adjustments within their role;

(d) Escalates concerns and complex cases appropriately;

(e) Completes required training;

(f) Contributes to a culture of fair treatment and good customer outcomes.

7.2 Vulnerable Customer Working Group

We establish a cross-functional Vulnerable Customer Working Group chaired by the COO and including representatives from:

• Compliance

• Operations

• Sales and Business Development

• Customer Service

• Product Development

• Risk Management

• IT/Digital

Meeting Frequency: Quarterly (minimum)

Responsibilities:

(a) Review vulnerable customer KPIs, trends, and outcomes;

(b) Discuss case studies, lessons learned, and best practices;

(c) Identify systemic issues or patterns requiring corrective action;

(d) Coordinate cross-functional improvement initiatives;

(e) Oversee implementation of policy updates or new initiatives;

(f) Ensure alignment between departments on vulnerability approach.

7.3 Culture and Values

We embed fair treatment of vulnerable customers into our organizational culture through:

(a) Leadership commitment: Senior leaders model empathy and prioritize vulnerable customer outcomes;

(b) Recognition and reward: Employees who demonstrate exceptional support for vulnerable customers are recognized and rewarded;

(c) Open communication: Staff feel comfortable raising concerns or asking for guidance without fear of criticism;

(d) Continuous learning: We view every interaction as an opportunity to learn and improve;

(e) Ethical decision-making: When in doubt, we ask "What is the right thing to do for this vulnerable client?" rather than "What is the minimum required by regulation?"

8. COMPLAINTS AND FEEDBACK

8.1 Complaints from Vulnerable Clients

Complaints from vulnerable clients are handled in accordance with our Complaint Handling Procedure (www.unicorncurrencies.com/complaints) with the following enhancements:

(a) Priority handling: Expedited resolution where delay could cause significant distress or harm;

(b) Empathetic response: Extra sensitivity and understanding in complaint correspondence;

(c) Plain language: Clear, jargon-free explanations of our findings and decisions;

(d) Communication preferences: Accommodating preferred communication channels (phone, email, letter);

(e) Extended timelines: Offering vulnerable clients more time to provide information or consider our response if needed;

(f) Support signposting: Providing information about Financial Ombudsman Service (FOS) / ADR Chambers Banking Ombuds Office (ADRBO) and independent complaint support services.

8.2 Root Cause Analysis

For complaints from vulnerable clients, we conduct thorough root cause analysis to determine:

(a) Was vulnerability properly identified?

(b) Were appropriate support measures provided?

(c) Did communication failures contribute to the issue?

(d) Was the product suitable for the client's circumstances and understanding?

(e) Were staff adequately trained and supported?

(f) Are there systemic issues requiring policy or process changes?

8.3 Learning from Complaints

(a) Complaint themes: Quarterly analysis of complaint themes to identify patterns;

(b) Case studies: Anonymized complaint case studies used in staff training;

(c) Corrective actions: Implementation of corrective actions to prevent recurrence;

(d) Feedback loop: Complaints inform policy reviews and continuous improvement initiatives.

8.4 Proactive Feedback Solicitation

We proactively solicit feedback from vulnerable clients:

(a) Post-interaction surveys: Short surveys after key interactions (onboarding, complex transactions, complaints);

(b) Focus groups: Periodic focus groups or interviews with vulnerable clients to understand their experiences and needs;

(c) Accessibility testing: Involving vulnerable clients in testing new digital tools or processes;

(d) Client panels: Establishing a client advisory panel including vulnerable clients to provide ongoing input.

9. PRODUCT AND SERVICE DESIGN

9.1 Embedding Vulnerability in Design

We embed vulnerability considerations into product and service design from the outset:

9.1.1 New Product Approval Process

All new products or services undergo a vulnerability impact assessment addressing:

(a) Target market: Is the product suitable for clients with lower capability or higher vulnerability?

(b) Complexity: Is the product easy to understand, or does it require specialist knowledge?

(c) Risk profile: Could vulnerable clients suffer disproportionate harm if things go wrong?

(d) Communication: Can key features, risks, and terms be explained clearly in plain language?

(e) Accessibility: Can the product be accessed via multiple channels (digital, phone, in-person)?

(f) Support needs: What additional support might vulnerable clients need to use this product safely?

(g) Alternatives: Are simpler or lower-risk alternatives available for vulnerable clients?

Outcome: Products are approved only if they can be delivered fairly to vulnerable clients or if clear exclusions/safeguards are in place.

9.1.2 Digital Services and Accessibility

Our website, client portal, and digital communications are designed to be accessible:

(a) WCAG 2.1 AA compliance: Meeting Web Content Accessibility Guidelines for accessibility;

(b) Screen reader compatibility: Ensuring compatibility with assistive technologies;

(c) Keyboard navigation: Full functionality available without mouse use;

(d) Color contrast: Sufficient contrast for users with visual impairments;

(e) Resizable text: Users can increase text size without loss of functionality;

(f) Simple navigation: Clear, intuitive menu structures and navigation;

(g) Plain language: Website content written in clear, simple language (reading age ~12 years);

(h) Alternative channels: Always offering phone and email support alongside digital channels for clients who struggle with technology.

9.1.3 Documentation and Disclosures

(a) Plain language summaries: All contracts, terms, and disclosures include plain-language summaries;

(b) Key facts boxes: One-page key facts summaries highlight critical information (fees, risks, cooling-off rights);

(c) Visual explanations: Diagrams, flowcharts, and examples to illustrate complex concepts;

(d) Readability: Documents designed for readability (font size, spacing, formatting);

(e) Multiple formats: Documents available in large print, audio, or other formats upon request.

9.2 Product Reviews and Updates

(a) Annual product reviews assess whether existing products are being used appropriately by vulnerable clients;

(b) Outcome data (complaints, losses, customer satisfaction) informs product refinements;

(c) Vulnerability lens: Product changes are assessed for impact on vulnerable clients before implementation.

10. CONTINUOUS IMPROVEMENT

10.1 Annual Policy Review

This Vulnerable Customer Policy is reviewed annually by the Vulnerable Customer Lead and approved by the Board, considering:

(a) Changes in regulation, FCA guidance, or industry standards;

(b) Findings from monitoring, audits, and complaints;

(c) Feedback from staff, clients, and stakeholders;

(d) Emerging best practices and innovation;

(e) Changes in our business model, products, or client base.

10.2 Industry Benchmarking

We benchmark our approach against:

(a) FCA good practice examples: Learning from firms recognized for excellence in vulnerable customer support;

(b) Industry initiatives: Participating in industry working groups, roundtables, and collaborative projects on vulnerability;

(c) Academic research: Engaging with research on vulnerability, behavioral economics, and consumer outcomes;

(d) Peer comparison: Informal peer learning with other financial services firms.

10.3 Innovation and Improvement Initiatives

We continuously explore opportunities to improve our support for vulnerable clients:

(a) Technology solutions: Exploring AI-driven tools for identifying vulnerability indicators, personalization engines for adaptive communications, or chatbots with vulnerability detection;

(b) Simplified products: Developing even simpler product offerings for clients with limited financial capability;

(c) Financial inclusion: Exploring ways to serve clients who might otherwise be excluded due to vulnerability;

(d) Partnership models: Collaborating with charities, community organizations, or fintech innovators to better serve vulnerable clients.

10.4 Staff Engagement

(a) Feedback mechanisms: Staff can suggest improvements to vulnerability policies or processes through regular channels (team meetings, surveys, suggestion boxes);

(b) Recognition: Staff who identify improvement opportunities or demonstrate exceptional support for vulnerable clients are recognized and rewarded;

(c) Champions network: Vulnerable Customer Champions share ideas and innovations across departments.

11. RELATED POLICIES AND RESOURCES

11.1 Internal Policies

This Vulnerable Customer Policy should be read in conjunction with:

(a) Code of Conduct and Ethics

(b) Treating Customers Fairly (TCF) Policy

(c) Complaint Handling Procedure: www.unicorncurrencies.com/complaints

(d) Anti-Bribery and Corruption Policy: www.unicorncurrencies.com/abc-policy

(e) Modern Slavery Statement: www.unicorncurrencies.com/modern-slavery-statement

(f) Data Protection and Privacy Policy: www.unicorncurrencies.com/privacy

(g) Master Services Agreement: www.unicorncurrencies.com/terms

(h) Safeguarding Policy: www.unicorncurrencies.com/safeguarding

11.2 External Resources

11.2.1 Regulatory Guidance

(a) FCA Guidance on Fair Treatment of Vulnerable Customers (FG21/1): https://www.fca.org.uk/publications/finalised-guidance/fg21-1-guidance-firms-fair-treatment-vulnerable-customers

(b) FCA Consumer Duty: https://www.fca.org.uk/firms/consumer-duty

(c) FCA Approach to Consumers: https://www.fca.org.uk/publications/corporate-documents/our-approach-consumers

11.2.2 Support Services

Debt Advice:

• StepChange (UK): https://www.stepchange.org | 0800 138 1111

• National Debtline (UK): https://www.nationaldebtline.org | 0808 808 4000

• Credit Counselling Canada: https://www.creditcounsellingcanada.ca | 1-888-527-8999

Mental Health:

• Samaritans (UK): 116 123 | https://www.samaritans.org

• Mind (UK): https://www.mind.org.uk | 0300 123 3393

• Crisis Services Canada: 1-833-456-4566

Bereavement:

• Cruse Bereavement Care (UK): https://www.cruse.org.uk | 0808 808 1677

Domestic Abuse:

• National Domestic Abuse Helpline (UK): 0808 2000 247

• Canadian Domestic Violence Hotline: 1-800-363-9010

Financial Capability:

• Money Helper (UK): https://www.moneyhelper.org.uk | 0800 011 3797

• Financial Consumer Agency of Canada: https://www.canada.ca/en/financial-consumer-agency.html

Business Support:

• Business Debtline (UK): https://www.businessdebtline.org | 0800 197 6026

• BDC Advisory Services (Canada): https://www.bdc.ca/en/advisory-services

12. CONTACT INFORMATION

12.1 Vulnerable Customer Lead

For questions about this policy or to raise concerns about vulnerable client treatment:

Vulnerable Customer Lead / Head of Compliance

Email: compliance@unicorncurrencies.com

UK Phone: +44 (20) 8064-0818

Canada Phone: +1 (548) 488-0818

12.2 Client Support

If you are a client who would like to discuss support for your individual circumstances, please contact:

Email: support@unicorncurrencies.com

UK Phone: +44 (20) 8064-0818

Canada Phone: +1 (548) 488-0818

Address (UK):
Client Services
Unicorn Currencies Ltd
4th Floor, Silverstream House, Fitzroy Street
London, W1T 6EB
United Kingdom

Address (Canada):
Client Services
Unicorn Currencies Limited
5577 153A Street, Suite 207
Surrey, V3S 5K7, British Columbia
Canada

13. POLICY APPROVAL

This Vulnerable Customer Policy has been approved by the Board of Directors of Unicorn Currencies Limited (Canada) and Unicorn Currencies Ltd (United Kingdom).

Approved by:

Signed:

Nazia M Thakur
CEO and Founder
Unicorn Currencies

Date: December 1, 2025

Next Review Date: December 2026 (or earlier if regulatory or business changes require)

This policy demonstrates Unicorn Currencies' commitment to fair treatment of all clients, with particular attention to those who may be in vulnerable circumstances. We recognize that vulnerability can affect anyone at any time, and we are committed to adapting our services to ensure all clients—including business decision-makers facing challenges—receive the support they need to achieve good outcomes.

© 2025 Unicorn Currencies. All rights reserved.